A. Lutz Financial is a limited liability company formed on February 2, 2000, in the State of Nebraska. Lutz Financial first registered as an investment adviser with the SEC in June 2003. Lutz Financial is principally owned by Ectart, LLC. James P. Boulay is Lutz Financial’s Managing Member and Chief Compliance Officer. B. As discussed below, Lutz Financial offers to its clients (generally, individuals, high net worth individuals, retirement plans, charitable organizations, and business entities), pension consulting and investment advisory services, and to the extent specifically requested by a client, financial planning and related consulting services. INVESTMENT ADVISORY SERVICES The client can engage Lutz Financial to provide discretionary or non-discretionary investment advisory services on a fee basis. Lutz Financial’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under Lutz Financial’s management. Prior to engaging Lutz Financial to provide investment advisory services, clients are required to enter into an Investment Advisory Agreement with Lutz Financial setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. Lutz Financial provides investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objectives. Thereafter, Lutz Financial will allocate or recommend that the client allocate investment assets consistent with their designated investment objectives. Once allocated, Lutz Financial provides ongoing monitoring and a review of account performance and asset allocation as compared to client investment objectives, and may rebalance the account as necessary based on such reviews. Lutz Financial primarily recommends or uses various mutual funds (including the mutual funds sponsored by Dimensional Fund Advisors (“DFA”)), individual bonds, exchange-traded funds (“ETFs”), in managing client accounts, based on the investment objectives of each client. Lutz Financial’s annual investment advisory fee includes investment advisory services, and, to the extent specifically requested by the client, financial planning and consulting services. In the event that the client requires extraordinary planning or consultation services (to be determined in the sole discretion of Lutz Financial), Lutz Financial reserves the right to charge for these additional services, pursuant to a stand-alone Financial Planning and Consulting Agreement (see below). FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE) Lutz Financial may provide financial planning or consulting services (including on investment and non-investment related matters, such as estate planning and insurance planning) on a stand-alone separate fee basis as described in Item 5 below. Prior to engaging Lutz Financial to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Lutz Financial setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Lutz Financial commencing services. If requested by the client, Lutz Financial may recommend the services of other professionals for implementation purposes, including the accounting services of Lutz Financial’s affiliate, Lutz & Company, P.C. and related entities (“Lutz & Company”). (See additional information about this affiliation at Item 10.C.). The client is under no obligation to engage the services of any recommended professional. The client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation from Lutz Financial. If the client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not Lutz Financial, shall be responsible for the quality and competency of the services provided. It remains the client’s responsibility to promptly notify Lutz Financial if there is ever any change in their financial situation or investment objectives so that Lutz Financial can review, and if applicable, revise its previous recommendations or services. RETIREMENT PLAN CONSULTING SERVICES Lutz Financial offers fiduciary and non-fiduciary retirement plan consulting services, on a discretionary or non-discretionary fee basis, to defined contribution, defined benefit and non-qualified plans. All qualified plan client accounts are regulated under the Employee Retirement Income Securities Act (“ERISA”). Lutz Financial will provide discretionary, non-discretionary, fiduciary and non-fiduciary advisory services to the sponsors of the defined contribution, defined benefit, and nonqualified deferred compensation plans, considering each plan’s stated objective, liquidity needs, and stated policies and guidelines. Lutz Financial employs an initial and ongoing screening process based upon various quantitative and qualitative factors, including performance and costs. Lutz Financial may be engaged to provide the following services (collectively, “Services”) to a company, plan or plan participant during the term of an engagement. Pooled Qualified Retirement Plan Fiduciary Services: Lutz Financial may be engaged to provide discretionary 3(38) investment management to clients regarding the investment management of pooled qualified retirement plans. Under this arrangement, Lutz Financial will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and accepts discretion over plan assets, while assuming full responsibility and liability for the fiduciary functions concerning decisions related to the plan assets. Lutz Financial’s services shall include the following, to the extent requested and agreed upon, in writing: i. Making discretionary investment decisions for Plan assets ii. Developing an investment policy statement iii. Creating periodic investment reports to aid in monitoring investments iv. Attending periodic meetings with the client to discuss reports v. Analyzing and recommending service providers vi. Reviewing and conducting due diligence relating to manager and fund selections vii. Attending meetings with custodian or record-keeper on matters pertaining to the plan investments viii. Participating in periodic committee meetings (or as often as the committee deems necessary) ix. Participating in additional sub-committee meetings as requested with members and outside advisors Defined Contribution Plan and Defined Benefit Plan Fiduciary Services: Lutz Financial may be engaged to provide non-discretionary 3(21)(a)(ii) investment advice to clients regarding asset classes and investment alternatives available to the client in accordance with its investment policies and objectives and to the extent written policies and objectives have been brought to the attention of Lutz Financial. When Lutz Financial is engaged in this capacity, the client shall have final decision-making authority regarding the selection, retention, removal and addition of investment options. Lutz Financial will not maintain discretionary authority or control, whatsoever, with respect to the plan or the plan participant accounts maintained by the plan. Lutz Financial will provide services only to the extent it receives necessary and timely cooperation from the company, including but not limited to meetings, telephone calls, production of documents, coordination of services and company decision-making assistance. Lutz Financial’s services shall include the following, to the extent requested and agreed upon, in writing: i. Assisting in selecting investment options ii. Assisting in the development of an investment policy statement iii. Providing periodic investment reports to aid in monitoring investment options iv. Attending periodic meetings with the client to discuss reports v. Assisting with the selection of qualified default investment alternatives vi. Analyzing and recommending service providers vii. Assisting with review and due diligence relating to manager and fund selections viii. Attending meetings with custodian or record-keeper on matters pertaining to the plan investments ix. Participating in periodic committee meetings (or as often as the committee deems necessary) x. Participating in additional sub-committee meetings as requested with members and outside advisors xi. Assisting with investment fund mapping and analytical support as requested Clients must acknowledge that Lutz Financial has no responsibility to provide any services related to the following types of assets: employer securities; ESOP Plans, real estate (except for real estate funds and publicly traded REITs); voting proxies, stock brokerage accounts or mutual fund windows; participant loans; non-publicly traded partnership interests; other non-publicly traded securities or property (other than collective trusts and similar vehicles); or other hard-to-value or illiquid securities or property (collectively, “Unmanaged Assets”). Defined Contribution, Defined Benefit Plan Non-Fiduciary Services: Lutz Financial may be engaged to provide non-discretionary, non-fiduciary services. When Lutz Financial is engaged in this capacity, the client shall have final decision-making authority regarding the selection, retention, removal, modification or addition of all advisor non-fiduciary recommendations. Lutz Financial’s services shall also include the following, to the extent requested and agreed upon, in writing: i. Monitoring and supporting governances ii. Assisting with plan administration and vendor management iii. Supporting participant communication and education program iv. Providing benchmark studies and searches v. Assisting with implementation and conversions vi. Analyzing client’s service provider reports AUTOMATED INVESTMENT PROGRAM Lutz Financial offers an Automated Investment Program (the “Program”) for certain clients who do not want ongoing planning and consulting services. This Program features asset management services delivered digitally, with access to online financial planning software for the client’s use. However, this program shall not include financial planning services. Clients who are members of the Program are invested in a range of investment strategies Lutz Financial has constructed and manages, each consisting of a portfolio of exchange- traded funds and mutual funds, and a cash allocation. The client may instruct us to exclude up to three Funds from their portfolio. The Client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“Schwab”). We use the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of Schwab, to operate the Program. Please Note: Lutz Financial, and not Schwab, is the Client’s investment adviser and act as the Client’s primary contact for the Program. Duties of implementation under this Program fall solely on the client. Lutz Financial is not responsible for implementation of advice provided under this Program. Additional details regarding the fee for the Program can be found at Item 5 below. MISCELLANEOUS Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, Lutz Financial may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance planning, etc. Lutz Financial does not serve as a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. Accordingly, Lutz Financial does not prepare estate planning documents or tax returns. To the extent requested by a client, Lutz Financial may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.), including Lutz Financial’s affiliate, Lutz & Company (See additional information about these affiliations at Item 10.C). The client is under no obligation to engage the services of any recommended professional. The client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation from Lutz Financial and/or its representatives. Please Note: If the client engages any recommended professional, and a dispute arises thereafter relative to that engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not Lutz Financial, shall be responsible for the quality and competency of the services provided. Please Further Note- Conflict of Interest: The recommendation by Lutz Financial representative that a client purchase an insurance product from a Lutz Financial representative in his/her individual capacity as a representative of an insurance agent, presents a conflict of interest. The receipt of commissions may provide an incentive to recommend insurance products based on commissions to be received, rather than on a particular client’s need. No client is under any obligation to purchase insurance commission products from a Lutz Financial representative. Clients may purchase insurance products through other insurance agents. Additionally, please note, Lutz Financial and its IARs may receive additional compensation for recommending clients to Lutz Financial’s affiliate, Lutz & Co. Please Note: Neither Lutz Financial nor any of its investment professionals are agent of record for insurance product referrals. Lutz Financial’s Chief Compliance Officer, James P. Boulay, remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. Use of Certain Mutual Funds and ETFs: Lutz Financial utilizes mutual funds and exchange traded funds for its client portfolios. In addition to Lutz Financial’s investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). The mutual funds and exchange traded funds utilized by Lutz Financial are generally available directly to the public. Thus, a client can generally obtain the funds recommended and/or utilized by Lutz Financial independent of engaging Lutz Financial as an investment advisor. However, if a prospective client does so, then they will not receive Lutz Financial’s initial and ongoing investment advisory services. Please Note-Use of DFA Mutual Funds: Lutz Financial utilizes the mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers approved by DFA. Thus, if the client was to terminate Lutz Financial’s services, and transition to another adviser who has not been approved by DFA to utilize DFA funds,

restrictions regarding additional purchases of, or reallocation among other DFA funds, will generally apply. Lutz Financial’s Chief Compliance Officer, James P. Boulay, remains available to address any questions that a client or prospective client may have regarding the above. Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Lutz Financial generally recommends that Charles Schwab and Co., Inc. (“Schwab”), and Nationwide Advisory (“Nationwide”) serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab and Nationwide charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab and Nationwide, do not currently charge fees on individual equity transactions, others do). When beneficial to the client, individual fixed‐income and/or equity transactions may be effected through broker‐dealers with whom Lutz Financial and/or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other SEC registered and FINRA member broker‐dealers (in which event, the client generally will incur both the transaction fee charged by the executing broker‐dealer and a “trade-away” fee charged by Schwab and/or Nationwide). These fees/charges are in addition to Lutz Financial’s investment advisory fee at Item 5 below. Lutz Financial does not receive any portion of these fees/charges. Retirement Plan Rollovers- No Obligation/Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Lutz Financial recommends that a client roll over their retirement plan assets into an account to be managed by Lutz Financial, such a recommendation creates a conflict of interest if Lutz Financial will earn new (or increase its current) compensation as a result of the rollover. If Lutz Financial provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Lutz Financial is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Lutz Financial. Lutz Financial’s Chief Compliance Officer, James P. Boulay, remains available to address any questions that a client or prospective client may have regarding the conflict of interest presented by such a rollover recommendation. Non-Discretionary Service Limitations. Clients that determine to engage Lutz Financial on a non-discretionary investment advisory basis must be willing to accept that Lutz Financial cannot effect any account transactions without obtaining prior consent to such transaction(s) from the client. In the event that Lutz Financial would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, Lutz Financial will be unable to effect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Variable Annuities (1035 exchanges): In limited circumstances, Lutz Financial may invest client assets in the investment sub-divisions of a variable annuity issued by Nationwide. Lutz Financial does not purchase variable annuities for its clients on a commission basis. Rather, Lutz Financial recommends that clients owning variable annuities consider a 1035 exchange to Nationwide, one of the nation's lowest cost, fee- only, variable annuity providers. By so doing, we seek to reduce the fees and expenses associated with commission-based annuities. The client retains absolute discretion over the decision to engage Nationwide and is free to accept or reject any recommendation from Lutz Financial and/or its representatives. Reporting Services. Lutz Financial may provide its clients with access to an online platform hosted by Orion or MoneyGuide Pro. The Orion and MoneyGuide Pro platforms allow a client to view their complete asset allocation, including those assets that Lutz Financial does not manage (the “Unmanaged Assets”). Lutz Financial does not provide investment management, monitoring, or implementation services for the Unmanaged Assets. Therefore, Lutz Financial shall not be responsible for the investment performance of the Unmanaged Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Unmanaged Assets, and not Lutz Financial, shall be exclusively responsible for such investment performance. The client may choose to engage Lutz Financial to manage some or all of the Unmanaged Assets pursuant to the terms and conditions of an Investment Advisory Agreement between Lutz Financial and the client. The Orion and MoneyGuide Pro platforms also provide access to other types of information, including financial planning concepts, which should not be viewed as services, advice, or recommendations provided by Lutz Financial. Finally, Lutz Financial shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the Orion or MoneyGuide Pro platforms without Lutz Financial’s assistance or oversight. Portfolio Activity. Lutz Financial has a fiduciary duty to provide services consistent with the client’s best interest. Lutz Financial will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Lutz Financial determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be no assurance that investment decisions made by Lutz Financial will be profitable or equal any specific performance level(s). Other Assets. A client may:
• Hold securities that were purchased at the request of the client or acquired prior to the client’s engagement of Lutz Financial. Generally, with potential exceptions, Lutz Financial does not/would not recommend nor follow such securities, and absent mitigating tax consequences or client direction to the contrary, would prefer to liquidate such securities. Please Note: If/when liquidated, it should not be assumed that the replacement securities purchased by the Lutz Financial will outperform the liquidated positions. To the contrary, different types of investments involve varying degrees of risk, and there can be no assurance that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Lutz Financial) will be profitable or equal any specific performance level(s). In addition, there may be other securities and/or accounts owned by the client for which Lutz Financial does not maintain custodian access and/or trading authority; and, Corresponding Services/Fees: When agreed to by Lutz Financial, Lutz Financial shall: (1) remain available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor these securities/accounts on a regular basis, including, where applicable, rebalancing with client consent; (3) shall generally consider these securities as part of the client’s overall asset allocation; (4) report on such securities/accounts as part of regular reports that may be provided by Lutz Financial; and, (5) include the market value of all such securities for purposes of calculating advisory fee. Cash Positions. Lutz Financial continues to treat cash as an asset class. As such, unless determined to the contrary by Lutz Financial, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Lutz Financial’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Lutz Financial may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Lutz Financial’s advisory fee could exceed the interest paid by the client’s money market fund. Cross Transactions. In limited circumstances, when determined to be in the best interest of its clients, Lutz Financial may arrange for cross-transactions pursuant to which Lutz Financial may cross transactions between two of its managed client accounts (i.e., arranging for the clients’ securities trades by “crossing” these trades when Lutz Financial believes that such transactions are beneficial to its clients). This may present a conflict of interest. For all such transactions, neither Lutz Financial nor any affiliate will be acting as a broker. Lutz Financial will not receive any commission or transaction-based compensation, although Lutz Financial has an interest in the price at which the cross trades are conducted since Lutz Financial’s asset-based fees will be negatively impacted by lower bond values. These transactions will be generally effected through Schwab, the account custodian. The client may revoke Lutz Financial’s cross-transaction authority at any time upon written notice to Lutz Financial. Cybersecurity Risk. The information technology systems and networks that Lutz Financial and its third-party service providers use to provide services to Lutz Financial’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Lutz Financial’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Lutz Financial are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Lutz Financial has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Lutz Financial does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker- dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of certain considerations into the investment due diligence process. Socially responsible investing incorporates a set of socially responsible criteria/factors used in evaluating potential investments, including environmental, social, and governance considerations. The number of companies that meet an acceptable socially responsible mandate can be limited when compared to those that do not, and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of socially responsible mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Lutz Financial), there can be no assurance that investment in socially responsible securities or funds will be profitable or prove successful. Lutz Financial does not maintain or advocate a socially responsible investment strategy, but will seek to employ socially responsible investments if directed by a client to do so. If implemented, Lutz Financial shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Client Obligations. In performing its services, Lutz Financial shall not be required to verify any information received from the client or from the client’s other designated professionals, and is expressly authorized to rely thereon. It remains the client’s responsibility to promptly notify Lutz Financial if there is ever any change in their financial situation or investment objectives so that Lutz Financial can review, and if applicable, revise its previous recommendations or services. Disclosure Brochure. A copy of Lutz Financial’s written Privacy Notice, written disclosure statement as set forth on Part 2A and 2B of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each client or prospective client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning and Consulting Agreement. Any client who has not received a copy of Adviser’s written Brochure at least 48 hours prior to executing such agreement shall have five business days subsequent to executing the agreement to terminate the Adviser’s services without penalty. C. Lutz Financial provides investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objectives. Thereafter, Lutz Financial will allocate or recommend that the client allocate investment assets consistent with their designated investment objectives. The client may impose reasonable restrictions, in writing, on Lutz Financial’s services. D. Lutz Financial does not participate in a wrap fee program. E. As of December 31, 2023, Lutz Financial had $2,021,734,628 in assets under management on a discretionary basis and $257,306,892 in assets under management on a non- discretionary basis for a total of $2,279,041,520 in assets under management.